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Guidelines on procedures for dealing with cultural property

This page provides additional guidance for staff and students dealing with cultural property. If you are in doubt at any stage, please seek advice, more ...

UCL Cultural Property guidleines



1. UCL has adopted a Cultural Property Policy to ensure compliance with national and international property laws.

2. UCL acknowledges its corporate responsibility for the cultural property that it owns or is on its premises. As a consequence all its staff (which, for the avoidance of doubt, includes employees, workers and honorary staff) and students have a personal responsibility for complying with the Policy.

3. To fulfil that obligation:

  • all staff and students should exercise care in dealing with the acquisition and use of cultural property related to their duties, studies or personal interests; and
  • UCL will maintain a Cultural Property Register which will record all cultural property owned by UCL or located on its premse
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4. The definition of Cultural Property in UCL's policy is a broad one: ‘individual objects, collections, specimens, structures, or sites identified as having artistic, historic, scientific, religious, or social significance, whether or not they are held and maintained principally for their contribution to knowledge and culture’.

5. Only ‘significant’ material needs to be included on the Register. To be significant cultural property is defined as:

  • material whose loss would represent a loss to the cultural heritage;
  • Iit has sufficient quality to be worthy of being acquired by a museum;
  • is of interest to the public;
  • it is relatively rare; or
  • it has been, or is being studied, for the purposes of research.

6. The circumstances under which cultural property may have been acquired are many:

  • to assist undergraduate teaching, whether or not part of a teaching collection;
  • as the subject for research by an individual member of staff or for a larger project which involves a research team;
  • for processing and publishing the results of field exploration and excavation;
  • as the product of laboratory or clinical procedures;
  • as gifts of friendship from alumni, sponsors, and friends of UCL;
  • for ornament for offices, communal spaces or other corporate real estate;
  • inadvertently, such as abandoned property on UCL premises.

7. The Cultural Property Register will include the following:

  • all land and buildings recognised as significant under national laws ('historic environment');
  • the collections of UCL's museums, and special collections held by UCL Library Services; and
  • cultural property held in academic and support service departments.

8. Cultural property which is the personal possessions of staff members and students fall within the scope of the Policy, unless it is, by common consent, of trivial academic or financial value. Staff wishing to keep other cultural property on UCL's premises must have the permission of the Vice-Provost (Academic and International). Where consent is given, they will be expected to undertake to indemnify UCL against loss or damage arising from such items being on UCL premises. Unless there is specific written agreement, UCL accepts no liability for cultural property held on its premises.

9. Any cultural property in the personal possession of staff but which is not in their ownership and for which no formal loan agreement exists shall be entered on the Register and treated as if it were on loanto UCL.

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10. UCL's Museums, Heritage & Cultural Property Committee is responsible for oversight of the Cultural Property Policy. Overall supervision is the responsibility of the Director of Finance.

11. The following accountable persons are responsible for the day-to-day administration of the Policy:

  • the Director of Estates, for historic environment entries;
  • the Director of Museums & Collections, for entries relating to UCL's museums and collections;
  • the Director of Library Services, for entries relating to UCL's Special Library Collections and Archives; and
  • Heads of Department, for entries relating to cultural property in academic, administrative and technical departments.

12. Responsibilities for day-to-day administration may be delegated to named post-holders or individuals.

13. The accountable persons must ensure that those people dealing with the acquisition of cultural property by whatever means must exercise due diligence in the following ways:

  • only to acquire cultural property from reputable sources;
  • be suspicious where, for no obvious reason, the purchase price appears to be lower than the market value;
  • by evaluating the information about the cultural property given by the donor/seller/lender;
  • by scrutinising the cultural property for any physical evidence, marks or labels that suggest:
    • may previously have been part of a collection,
    • may have been recently excavated in an illicit manner,
    • it has been taken from a larger object, or a building or ancient monument;
    • by examining documentation and other written evidence; and
    • by checking the cultural property against published databases of lost or stolen item
14. This duty of care will be higher when the material originates in areas of the world which have, or are, experiencing significant levels of spoliation of cultural property, or it belongs to a category of objects considered to be at special risk of illicit traffic.

15. Where there is any doubt, accountable persons must ensure that advice is sought from experts in the field, either in the UK or other country of origin. Advice on sources of advice is available from the Director of Museums and Collections for artefacts, specimens and works of art, and the Director of Library Services for library and archive material.

16. Accountable persons are required to ensure that the details of the cultural property on the Register are maintained up-to-date, including:

  • long-term relocation of the cultural property within UCL premises;
  • transfer of responsibility for the cultural property to other accountable persons; and
  • disposal of cultural property

17. Staff members and students are required to follow the Cultural Policy. In particular:

  • staff should not let their obligations in respect of the Policy conflict with activities they undertake in their private time; and
  • where, in their own time, they participate in activities such as fieldwork, exploration or activities, whether in the UK or elsewhere, they are required to ensure that all these activities are legal and that all finds and discoveries are reported to the appropriate authorities.

18 In the case of any uncertainty staff and students are encouraged to take advice from the Director of Museums & Collections, or the Director of Library Services, as appropriate.

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Existing Holdings

19. Accountable persons are required to ensure that all cultural property already owned by or kept on UCL's premises are entered into the Register. As a minimum, the details to be provided should include:

  • a short title and description of the cultural property;
  • its location; and
  • the circumstances of its acquisition (if known); and
  • an indicative valuation, if available.

20. It is expected that all existing holdings should be added to the Register by 31 July 2010. Any cultural property on UCL premises before that date but not located or identified until afterwards should be added to the Register in a timely manner.

21. The documentation of UCL's Library, museum and other collections will constitute the Register entries for that cultural property

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New Acquisitions

22. UCL’s Museums and Library have adopted acquisition and disposal policies that relate to their own specific circumstances which govern the acquisition of material for their own collections.

23. UCL has the right to refuse gifts, bequests or loans, whether conditional or otherwise. Before accepting a donation or loan of cultural property, accountable persons should establish the following:

  • the archaeological, historical, aesthetic, scientific or literary value of the cultural property;
  • where the cultural property will be kept, and under what conditions; and
  • the costs of its maintenance (including any applicable overhead costs)

24. Accountable persons should send to the Director of Finance copies of all correspondence with donors/lenders, where serious consideration is being given to acquire cultural property.

25. In every case, donors, sellers or lenders must provide written evidence that they are the legal owner of the cultural property.

26. All cultural property must not have been exported in violation of the laws of the country in which it originated at any time . This must be confirmed by:

  • for items exported from the originating country pre-1970, contemporary documentary evidence demonstrating that it was exported legally that, or where there is no such documentation, by an affidavit stating the grounds for the belief that the object was exported legally; or
  • for items exported from the originating country after 1970, documentary evidence in the form of valid export permits, licences or customs documentation e stablishing that it was legally exported from its country of origin.

25. Valid documentation in both circumstances is that issued by a competent authority in the country of origin. The term 'competent authority' includes both persons and agencies that have been invested with the powers, or is otherwise legally delegated, to perform a designated function. The nature of these authorities differ from jurisdiction to jurisdiction (and in some cases permission may be required from more than one competent authority), but examples are: Heads of State;

  • government ministers;
  • provincial governors;
  • state antiquities services;
  • superintendenze of cultural heritage;
  • environment and heritage agencies;
  • customs authorities.

27. UCL staff must not compete with the University to acquire cultural property, whether on the open market or by private treaty.

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28. The Register shall be in the form of a perpetual record, and include details of provenance, previous ownership, and import and export documentation. Details of this evidence shall be retained after any disposal of property on the Register, or its return to donors.

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29. The Director of Finance must be advised of all Cultural Property, using the Cultural Property Reporting Form. When there are complicating circumstances surrounding the acquisition, this form must be submitted before accepting the gift or loan.

30. The Director of Finance will seek guidance from UCL's Director of Museums & Collections or Director of Library Services when a potential gift/loan raises sensitive issues for UCL or involves questions regarding policy.

31. Unless there are matters which need to be resolved, the cultural property will be added to the Register. Copies of all correspondence, purchase invoices, should be forwarded for inclusion with the Register.

32. All acquisitions by gift or purchase should be acknowledged by the accountable person to include:

  • a brief description of the property, including is completeness and condition (and where constituted as different items the number of those items, or some other appropriate means of describing the nature and quantity of the property);
  • the reason for acquisition;
  • any terms and conditions agreed between both parties;
  • in the case of acquisition by gift or sale
    • the agreed purchase price (when a sale);
    • the position of any Intellectual Property Rights, which should normally be acquired along with the cultural propert

    in the case of loans,
    • the agreed return date
    • insurance arrangements and
    • statement indicating that UCL will take the same care and precautions for the protection of the property whilst they are on its premises as it does for other cultural property it holds on loan, and
    • except in the case of negligence on its own part, or that of its employees, workers or agents. UCL does not accept liability for the loss of, or damage to, or deterioration in, the property

33. The Director of Finance can provide copies of gift and loan forms approved for this purpose for use by the accountable person, if this is preferred.

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Cultural Property acquired by Field Collection

34. Cultural property acquired as a result of field exploration or excavation may come to UCL for processing and publication prior to its return to the locality or country from where it originated.

35. Such items should be treated as if they were a loan, and the appropriate procedures followed.

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Cultural Property acquired by Laboratory or Clinical Procedure

36. Cultural Property created by laboratory or clinical procedure shall, unless there are other contractual or legal obligations that preclude it, come into the ownership of UCL.posals

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37. Disposals from UCL's museums and collections and Library Services fall within the scope of the Disposals policies of those departments.

38. Other disposals of cultural property will be guided by the purpose for which the property was acquired and, in the case of gifts, any conditions or limitations imposed by the Donor.

39. Other than items held in UCL's museum, gallery or library collections, cultural property shall be disposed of in the manner which generates the most benefit to UCL's mission, which may include:

  • transfer, whether by gift, sale or loan, to another public institution;
  • public sale to achieve the best market price;
  • destruction, where one or more of the following apply to the cultural property:
  • of trivial intellectual or financial value, and/or
  • it is in a poor condition and the costs of repair are prohibitive, and/or
  • duplicates an item held elsewhere in UCL; and/or
  • may pose a real hazard to human health or the environment

40. No item on the Register shall be disposed of:

  • in the case of the Museum or Library Collections, without going through the process specified in the appropriate Disposal Policy; or otherwise
  • at the instruction of a single individual;
  • without the consent of either the Director of Museums & Collections, or Director of Museums & Collections, whosever shall be the most appropriate, and who, in making a decision, shall have taken advice on all aspects of the proposed disposal;
  • where the cultural property has been accepted on the basis of terms and conditions that disposal would break, without the consideration of the Museums, Collections & Cultural Property Committee and the specific consent of Council.

41. UCL staff must not acquire cultural property UCL has decided is redundant without going through a transparent disposal process.

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Forms: each link opens a separate Word document

Cultural Property Checklist - click here
Complete this if you are unsure about whether an item or group constitutes cultural property

Permission to Acquire Cultural Property - click here
All cultural property acquired for or kept at UCL must be recorded on a central Register, so as to ensure that in holding such items UCL is not breaking the law. All staff or students acquiring cultural property (whether single items or groups of items) for any purpose MUST secure approval in advance. Completed forms should be submitted to the Director of Finance via the Accountable Person in your department

Incoming Loan Form - click here
This is a record of any loan of cultural property entering UCL. It should be signed by a member of staff in the department and by the lender. A copy should be submitted to the Director of Finance via the Accountable Person in your department

Transfer of Title form - click here
This is a record of the gift or sale of cultural property to UCL. It should be signed by a member of staff in the department and by the existing owner. A copy should be submitted to the Director of Finance via the Accountable Person in your department

Outgoing loan or Disposal Form - click here
This is a record of the disposal of an item of cultural property whether owned by or lent to UCL. This form should be completed as a record once the item has been approved for disposal.

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Flowcharts: each link opens a separe document

  • What to do if you are offered cultural property for UCL - click here
  • What to do if the cultural property is already on the premises - click here
  • The role of the Accountable Person in each department - click here
  • The role of the Finance Department in maintaining the Register - click here
  • What to do if you need to dispose of cultural property - click here

>>>> to download the complete Guidelines document - click here

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This page last modified 23 March, 2010 by [Content Provider]

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